ClayClayLast Update: July 18, 2022
Clay Software Corporation (“Clay”, “we”, or “us”) values and respects your privacy. We have prepared this privacy policy to describe the manner in which we collect, use and disclose personal information in the course of providing our services and platform to our customers, through our website located at www.launchclay.com (the “Website”), as well as through other interactions with us.
Clay collects and uses personal information primarily on behalf of and in the course of providing services to our customers. In certain limited contexts, we may collect personal information on our own behalf, such as in connection with visits to our Website, job applications, and to send marketing communications.
Information we process on behalf of our customers:
Provision of Services: We provide an enterprise-level platform for builders to manage the sale and marketing of their construction project sites with an immersive 3D virtual world experience for their prospective and current customers. In the course of providing these services, we collect, use and disclose personal information that our customers upload or otherwise provide to us, including personal information about their prospective and current clients. This may include full name, home address, email address, phone number, occupation, date of birth, government-issued identity number (such as drivers license, passport, PR card), purchase details (such as suite number, lot number, model and elevation, unit number, finishes list, structural list, price and closing date), copies of purchase and sale agreements, and appointment details. As part of our services, we may also assist customers in sending marketing emails to prospective and current clients. If you have any questions about marketing emails sent by our customers or our customers’ privacy practices, please contact the customer directly.
Identity Verification Services: As part of our service, we offer the ability for our builder clients to verify the identity of their purchasers and authenticity of identity documentation for the purposes of complying with regulatory requirements. We use a third-party identity verification provider to verify the authenticity of government-issued ID and the identity of the purchaser. The identity of the purchaser is verified by collecting a photo of government-issued identification through a webcam or by uploading a picture and verifying that the name and photo on the identification matches the information provided by the purchaser, including a real-time selfie uploaded by the purchaser. We and our partner do not store any biometric data for this purpose.
Use of the Services: We may monitor use of the services by our customers or other authorized users to detect, investigate or prevent any actual or potential violation of our terms and conditions. We may also generate aggregated, non-identifiable data and use such information to monitor the performance, use and stability of the services and to improve the services.
Builder Profiles: We also create and maintain builder profiles, which are accessible to clients.
Our customers are responsible for providing all required notices, obtaining all necessary consents, and otherwise complying with applicable privacy laws with respect to the collection, transfer and use of personal information in connection of our provision of services to them. We retain personal information for as long as necessary to provide services to our customers and in accordance with our contractual commitments to our clients. We do not use or retain the information we collect from our customers for purposes other than providing the services.
Information we collect and use through our Website and other interactions:
We may collect personal information when you:
We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.
Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website and virtual machines, providing cloud and e-signature services, processing payments, verifying identification, and providing advertising analytics and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada, or other foreign jurisdictions.
Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property. Where a disclosure of our customers’ information is required by applicable law, we notify our customer prior to complying with such requirements (to the extent we are not prohibited from doing so) and co-operate with our customer’s instructions with respect to our response.
Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Clay or as part of a corporate reorganization or other change in corporate control.
Visiting our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.
Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.
Analytics: We may use a third-party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:
Third-Party Links: Our Website may contain links to other websites that Clay does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.
We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes of providing services to our customers or, with respect to the Website, for the purposes set out in this privacy policy, or to otherwise meet legal requirements.
As indicated above, if you have signed-up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below.
If we receive a request from an individual to access or update personal information we maintain on behalf of a customer, we will direct that individual to the relevant customer. We will assist our customers wherever possible in responding to individual access requests.
Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody or control and to withdraw your consent to our collection of your personal information (subject to legal and contractual restrictions). You may request access, updating and corrections of inaccuracies in your personal information in our custody or control, or withdraw your consent, by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.
If you have any questions or comments about this privacy policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to or correction of your personal information, or to withdraw your consent, please contact us at:
Privacy Officer
416-913-9075
privacy@launchclay.com
If you have any questions regarding the personal information we process on behalf of one of our customers, we encourage you to first contact the customer directly and/or review their applicable privacy policy.
